EU is preparing a wave of energy transmission investment (in the range of 100bn Euros). Is the existing transmission regulatory frame able to deal with this unprecedented financing needs?

1. A regulatory frame to support a
wave of investments in the EU?
Jean – Michel Glachant
Loyola de Palacio Prof. in EU energy Policy
Director Florence School

2. The issue: an EU wave of investment
Wave of investments for:
•Interconnecting the internal market
•Integrating massive Renewables
•Deploying technological change (smart this… /
smart that…)
It is unprecedented since… a while

3. No Reg. change or big Reg. change?
• No Regulatory change needed?
Super Optimism: because grid companies are regulated.
Hence do what they are told to do (“control and
command”).
• Big Regulatory change expected
Super Realism: because existing regulatory frame has not
been conceived to steer a wave of investments & tech.
innovation = it doesn’t push for effective wave of
investments and Tech. innovation

4. Two holes in our regulatory frame
• (1) Our regulation ultimate aim was & is “Low-ering all-
Cost”.
Model Ryanair or Easyjet for Opex + a break on Capex
What for a wave of investments & Tech. innovation?
• (2) Regulation of investments is only national
As if EU internal market was only a by-product of
national interests
What for EU internal market & regional initiatives?

5. A wave of four regulatory
challenges?
• Coordination of our massive investments
• Economic efficiency of our regulatory frame
• Financial feasibility of an investment wave
• Handling of (massive?) redistributive effects

6. 1st Reg. Challenge: Coordination
• (1)TRSM investment complement to Generation (“favors” G)
¤ also substitute to G (“kills” or “deters” G) ¤¤ massive TRSM
investment > massive effects on G
• (2) Social value of TRSM = f(G) ¤ social value of massive
TRSM invest = f(G) ¤¤ To get the max from TRSM invest we
also need a max from G
• (3) Critical to coordinate TRSM and G: How? ??
• (4) How to coordinate cross-border invest in TRSM & G? @
EU level? Region? North Sea Off-Shore

7. 2nd Reg. Challenge: Economic
Efficiency of Existing Reg. Frame
• (1) Incentive regulation gives incentives…
Price Cap calls for – Costs for a given Output (given set of
services). It targets - OPEX while bypassing CAPEX
(assuming – Investments)
• (2) No reg. frame for new set of ++services with massive
investment and Tech. innovation
New set of services ¤> new set of Key Performance Indicators
(KPI)?
>¤¤ To buy new grid services through new KPI?
>¤¤¤ To go from Price Cap on a given menu to Shopping Price “à
la carte” + service volume targets? (Performance based
regulation)

8. Economic efficiency (Cted)
• (3) What to do with CAPEX efficiency?
¤We did: “invest less for same set of services”
¤¤May we do: “pay less for any invest. volume”
• (4) Reducing CAPEX for given investment =
primarily to lower Capital Costs = to lower the
risk of investment… while innovation might
increase risk anyhow
• (5) Reducing risks by guaranteeing better
revenues? By giving longer term contracts 10-15
Years ?

9. Economic efficiency (end)
• (6) To invest less for same target of new services?
¤ to really incentivize grid services users?
¤¤ To abandon “low direct pricing” / “high
socialization tariffs”: “Shallow Costs”>“deep
costs”?
¤¤¤ To quit “Light Generation charge / Heavy Load
charge” for “Heavy G / Light L”?
¤¤ ¤¤ How to embark in massive investment if grid
users do not feel & care about the costs of their
individual provision of new services?

10. 3d Regulatory Challenge:
Financial feasibility of an investment wave
Could existing Reg. frame deliver wave financing?
With low tariffs how to attract wave investments?
• (1) Could publicly owned companies borrow more? Did
they already reached their Debt limits?
• (2) May we favor their cash flow with faster
amortization? May public owner inject new equity?
• (3) May they swallow real wave of investments with no
tariff increase?

11. Financial feasibility (Cted)
Could private companies attract investments?
• (1) What ROR level to raise new money?
• (2) What good ratio Debt / Equity to boost the Return
on Equity with a low ROR? Ratio dividends to
benefits? Financially acceptable? Socially acceptable?
Politically credible (for decades ahead)?
• (3) May they swallow real wave of investments with
no significant tariff increase?

12. Financial feasibility (end)
How to combine new wave of investments with actual portfolio
of existing assets? Could we isolate the new assets from the old?
•(1) a radical move is to go for massive “project financing”?
Groups of new assets are lodged in ad hoc companies isolated
from existing grids and open to new investors
•(2) These new investment vehicles are offered an ad hoc
regulatory frame (ROR, Amortization, TOTEX Cap, length of
contracts; rules of contract revision; etc.)
•(3) The national Reg. frame is potentially broken: investors from
anywhere can enter the investment race. National TSOs are
offered to self-internationalize by investing abroad.
•(4) Cash trapped or tightly regulated TSOs are pushed in
“Indian reserves” (old regulatory frame, low return, no
expectation of turn over or revenue growth)

13. 4th Reg. Challenge: Handling of (massive?)
redistributive effects
• (1) As TRSM invest is complement and substitute to
Generation – massive TRSM invest will allow massive Gen.
changes:
¤ Gen. marginal costs and merit order
¤¤ Market value of Gen. assets
¤¤¤ Market prices of electricity (day-ahead, intra-day, balancing
and ancillary services)

14. (Massive?) redistributive effects (Cted)
• (2) With massive changes for costs, merit order, revenues
and market prices, allocation of the benefits and costs of
new investments to become very hot potato
• (3) Whom to target & whom to favor? National G or
Foreign G? National Load or Foreign L?
• (4) Eurocrats (like me) see an EU social welfare. Whom at
national level sees anything else that national welfare? Even
sub-national (Scotland, Catalonia, Flanders, Bavaria)
• (5) Coming EU Cost-Benefits-Analysis methodology likely
to bypass the national and inter-national welfare
redistribution issue? How could national regulators bypass
it? Could ACER actually settle all the inter-regulatory
conflicts?

15. (more or… less) To conclude
• (1) A massive wave of investments can only have massive
consequences
• (2) Four substantial regulatory challenges arise: coordination
of investments; economic efficiency of regulation; financial
feasibility; handling of redistributive effects
• (3) A wave of massive investments could less be a dream
than… four serious headaches for our beloved regulators